News & Analysis as of

Constitutional Challenges Banking Sector Statutory Interpretation

Orrick, Herrington & Sutcliffe LLP

Bank responds to CFPB’s amended complaint and alleges improper delay tactics

On March 17, a bank again asked the U.S. District Court for the Northern District of Texas to dismiss the CFPB’s suit against the bank. As previously covered by InfoBytes, the Bureau filed an amended complaint after the...more

Ballard Spahr LLP

Petition for certiorari filed by State National Bank of Big Spring raising constitutional challenge to CFPB

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A petition for certiorari was filed in the U.S. Supreme Court late last week by State National Bank of Big Spring (SNB) which, together with two D.C. area non-profit organizations that also joined in the petition, had brought...more

Ballard Spahr LLP

D.C. Circuit Rules CFPB's View of RESPA Was Wrong but Its Structure is Constitutional

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On January 31, 2018, the en banc D.C. Circuit handed down its opinion in the PHH v. CFPB case, which we've discussed at length. It held, 7 to 3, that the CFPB's single-director-removable-only-for-cause structure is...more

Dorsey & Whitney LLP

D.C. Circuit Upholds CFPB’s Constitutionality: Why the PHH Case Underscores the Importance of Internal Agency Discipline

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On January 31, the U.S. Court of Appeals for the D.C. Circuit issued a plurality opinion en banc that confirmed the constitutionality of the Consumer Financial Protection Bureau’s (“CFPB”) governance by a sole Director, while...more

Ballard Spahr LLP

D.C. Circuit Rules CFPB’s View of RESPA Was Wrong But its Structure is Constitutional

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On January 31, 2018, the en banc D.C. Circuit handed down its opinion in the PHH v. CFPB case, which we’ve discussed at length. It held, 7 to 3, that the CFPB’s single-director-removable-only-for-cause structure is...more

Bricker Graydon LLP

PHH’s hidden gem

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The long-awaited en banc decision in PHH Corp., v. CFPB has finally been issued. The Court of Appeals for the D.C. Circuit upheld the constitutionality of the Consumer Financial Protection Bureau (CFPB) and reversed a prior...more

Morrison & Foerster LLP

PHH v. CFPB: Beyond the Headlines, A Big Win For Industry

There was something for everyone in the long-awaited decision from the en banc D.C. Circuit in PHH Corp. v. CFPB. In the part of the decision that has garnered widespread attention, the D.C. Circuit held that the structure of...more

Ballard Spahr LLP

Kerfuffle on statute of limitations issue in PHH case

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On June 7, the CFPB submitted a Rule 28(j) letter to the D.C. Circuit in the PHH case. In the letter, the CFPB embraced the fact that the Supreme Court’s recent Kokesh v. SEC decision makes the five-year statute of...more

Ballard Spahr LLP

D.C. Circuit Publishes Transcript of PHH v. CFPB Oral Arguments

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On June 6, 2017, the D.C. Circuit published the 85-page transcript of the May 24, 2017 oral arguments in the PHH v CFPB case...more

Ballard Spahr LLP

D.C. Circuit poised to decide constitutionality of CFPB structure in PHH case

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On May 24, 2017, the US Court of Appeals for the D.C. Circuit (D.C. Circuit) held oral argument in the PHH case, which we have blogged about extensively. The constitutionality of the CFPB’s structure was the central issue at...more

Ballard Spahr LLP

Richard Cordray’s tenure as CFPB Director is uncertain

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Clients are always asking me and others in our Consumer Financial Services Group about how long Richard Cordray will remain as CFPB Director. The short answer is nobody knows, perhaps not even Richard Cordray. ...more

Ballard Spahr LLP

The Framers did not rest our liberties on “bureaucratic minutiae,” PHH argues

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PHH filed its reply brief with the D.C. Circuit on April 10 in the en banc rehearing of the PHH case. We have blogged extensively about the case since its inception. Central to the case is whether the CFPB’s...more

Ballard Spahr LLP

Director Corday’s appearance before House Committee: strong on theater, weak on substance

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Despite its long duration (over five hours including a recess for a vote), the House Financial Services Committee’s hearing on April 5 at which Director Cordray was the sole witness provided a strong dose of political theater...more

Ballard Spahr LLP

DOJ seeks leave to participate in PHH en banc rehearing oral argument

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The Department of Justice, with the consent of PHH and the CFPB, has filed an unopposed motion with the D.C. Circuit requesting ten minutes of argument time in the oral argument to be held on May 24, 2017 in the rehearing en...more

Ballard Spahr LLP

CFPB Says Individual Liberty is Not a Relevant Consideration in the Constitutional Analysis of its Structure

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On March 31, the CFPB and supporting amici submitted their briefs in the en banc rehearing of the PHH case. We have blogged extensively about the PHH case in which the D.C. Circuit is grappling with four critical issues: (i)...more

Ballard Spahr LLP

Consumer advocacy groups, members of congress, and legal scholars file amicus briefs in support of the CFPB’s constitutionality

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Several individuals and organizations filed amicus briefs in support of the CFPB in the en banc rehearing in the PHH case. Among the amici is a brief filed by current and former members of Congress, including Chris Dodd and...more

Bilzin Sumberg

The New Administration's Plans for the CFPB Take Shape

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For those who have been wondering—as I did in a previous post—what the new presidential administration would mean for the Consumer Financial Protection Bureau (CFPB), an agency that has been in Republicans’ crosshairs...more

Ballard Spahr LLP

Process vs. Outcomes Debated at Hearing on Constitutionality of CFPB Structure

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As we had indicated, on March 16, the subcommittee on Oversight and Investigations of the House Financial Services Committee conducted a hearing entitled “The Bureau of Consumer Financial Protection’s Unconstitutional...more

Stinson - Corporate & Securities Law Blog

Justice Department Tells Court CFPB is Unconstitutional

The Department of Justice has filed an amicus brief in the case of PHH Corp. v. Consumer Financial Protection Bureau pending before the United States Court of Appeals for the District of Columbia Circuit and is scheduled for...more

Ballard Spahr LLP

Trump’s DOJ supports striking Cordray’s removable-only-for-cause protection from Dodd-Frank

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The DOJ submitted its amicus brief in the PHH case on Friday, March 17.  We have blogged extensively about this case since its inception. Unsurprisingly, the Trump DOJ supports striking from Dodd-Frank the...more

Ballard Spahr LLP

PHH files opening en banc brief; seven supporting amicus briefs filed

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On Friday, PHH filed its opening en banc brief with the D.C. Circuit in the rehearing of its appeal of Director Cordray’s June 2015 decision that affirmed an administrative law judge’s (ALJ) recommended decision concluding...more

Ballard Spahr LLP

D.C. Circuit grants motion of U.S. for leave to file amicus brief in PHH by March 17; denies motions to intervene

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The D.C. Circuit has entered an order granting the unopposed motion of the United States for leave to file an amicus brief in PHH by March 17, 2017.  As we previously observed, the motion appears to signal the DOJ’s intention...more

Ballard Spahr LLP

Motion filed by U.S. seeking leave to file amicus brief by March 17 signals support for PHH

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The United States, at the Solicitor General’s request, has filed an “unopposed motion” with the D.C. Circuit for leave to file an amicus brief in PHH by March 17, 2017.  The motion states that both PHH and the CFPB have...more

Ballard Spahr LLP

PHH opposes intervention by plaintiffs in another case challenging CFPB’s constitutionality

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PHH has filed a response opposing the motion of the plaintiffs in State National Bank of Big Spring, Texas, et al. v. Lew to intervene in the en banc rehearing.  The D.C. Circuit granted the CFPB’s petition for en banc...more

Ballard Spahr LLP

Plaintiffs in Another Case Challenging CFPB's Constitutionality Move to Intervene in PHH Case

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The plaintiffs in State National Bank of Big Spring, Texas, et al. v. Lew have filed a "Motion To Intervene In Any En Banc Proceeding That May Be Granted" in the PHH case. The motion follows the D.C. federal district court's...more

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